V20667 - Pinal County, Arizona · PDF file ·...

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S:\Word\PERMITS\Issued.v\V20667.ISS.docx V20667.000

1 (6/30/16) ARIZONA PUBLIC SERVICE – CASA GRANDE

SUNDANCE POWER PLANT - CASA GRANDE

1. INTRODUCTION ............................................................................................................................................. 4

2. LISTING OF (FEDERALLY ENFORCEABLE) APPLICABLE REQUIREMENTS ........................................................... 4

3. PROSPECTIVE COMPLIANCE REQUIREMENTS ................................................................................................ 6

A. COMPLIANCE PLAN ................................................................................................................................................ 6 B. COMPLIANCE SCHEDULE ......................................................................................................................................... 6

1. Risk Management Program and Plan .......................................................................................................... 6

4. AUTHORITY TO CONSTRUCT .......................................................................................................................... 6

A. CT SYSTEM REQUIREMENTS .................................................................................................................................... 7 B. PSD EMISSION LIMITS ............................................................................................................................................ 8

1. Definitions .................................................................................................................................................... 8 2. Emission Limitations and Associated Requirements .................................................................................... 8

C. FUEL USE LIMITATIONS ......................................................................................................................................... 10 1. CT Fuels ...................................................................................................................................................... 10 2. Diesel Driven Fire Pump.............................................................................................................................. 10

D. TIMING AND PROGRESS OF CONSTRUCTION .............................................................................................................. 10

5. EMISSION LIMITATIONS AND CONTROLS .................................................................................................... 10

A. APPLICABLE LIMITATIONS ...................................................................................................................................... 10 B. ALLOWABLE EMISSIONS ........................................................................................................................................ 11 C. EMISSION LIMITS ................................................................................................................................................. 11

1. NSPS Subpart GG Limitations ..................................................................................................................... 11 2. NESHAP Limitations on Emergency Compression Ignition Engines ............................................................ 11

D. FUEL-BURNING EQUIPMENT - PARTICULATE EMISSIONS .............................................................................................. 12 1. SIP Limitation ............................................................................................................................................. 12 2. Current Code Limitation ............................................................................................................................. 12

E. PARTICULATE EMISSIONS - CONTROL OF FUGITIVE DUST ............................................................................................. 12 F. GENERALLY APPLICABLE OPACITY LIMITS .................................................................................................................. 13

1. SIP Limitation ............................................................................................................................................. 13 2. Visibility Limiting Standard ......................................................................................................................... 13 3. Code Limitation ROTATING EQUIPMENT ONLY .......................................................................................... 13

G. REASONABLE PRECAUTIONS ................................................................................................................................... 14 H. SURFACE STABILIZATION ....................................................................................................................................... 14 I. ADDITIONAL PLANT-WIDE REQUIREMENTS ............................................................................................................... 15

1. Sandblasting - Plant Wide .......................................................................................................................... 15 2. Architectural Coatings ................................................................................................................................ 16 3. Other Spray Painting .................................................................................................................................. 16 4. Disposal ...................................................................................................................................................... 16 5. Cutback and Emulsified Asphalt ................................................................................................................. 16 6. Solvent Cleaning ......................................................................................................................................... 17



K. GENERALLY APPLICABLE LIMITS .............................................................................................................................. 18 1. Asbestos NESHAP Compliance .................................................................................................................... 18 2. Stratospheric Ozone and Climate Protection ............................................................................................. 18

L. ACID RAIN REQUIREMENTS .................................................................................................................................... 18 M. EMERGENCY RISK MANAGEMENT AND EMERGENCY RESPONSE PLAN REQUIREMENTS .................................................. 19

1. Chemical Accident Prevention Requirements ............................................................................................. 19

6. COMPLIANCE DEMONSTRATION ................................................................................................................. 19

A. TESTING............................................................................................................................................................. 19 1. Performance Test Methodology ................................................................................................................. 20 2. Performance Test Methods ........................................................................................................................ 20 3. Performance Testing Schedule ................................................................................................................... 21 4. Test Protocol .............................................................................................................................................. 21 5. Performance Test Notices .......................................................................................................................... 21

B. MONITORING ..................................................................................................................................................... 22 1. Instrumental emissions monitoring - oxides of nitrogen ............................................................................ 22 2. Instrumental emissions monitoring - Carbon monoxide ............................................................................ 22 3. General parametric emission monitoring requirements ............................................................................ 23 4. Parametric emissions monitoring - Volatile organic compounds ............................................................... 24 5. Parametric Emissions monitoring - Particulate matter .............................................................................. 24 6. Parametric emissions monitoring - sulfur dioxide ...................................................................................... 24 7. Periodic monitoring - Emergency Fire Pump Fuel Sulfur Content. .............................................................. 25 8. Parametric emission monitoring - Minimum Load Operation .................................................................... 25 9. Parametric emission monitoring - General Maintenance .......................................................................... 25 10. Parametric emission monitoring - Operating Cycle ............................................................................... 25 11. Parametric emission monitoring - Startup Events ................................................................................. 25

C. NESHAP MONITORING AND COMPLIANCE FOR EMERGENCY COMPRESSION IGNITION ENGINES ......................................... 25 D. RECORDKEEPING ................................................................................................................................................. 27 E. COMPLIANCE REPORTING ...................................................................................................................................... 28 F. REGULAR COMPLIANCE/COMPLIANCE PROGRESS CERTIFICATION .................................................................................. 28

7. OTHER REPORTING OBLIGATIONS ............................................................................................................... 29

A. DEVIATION REPORTING REQUIREMENT .................................................................................................................... 29 B. ANNUAL EMISSIONS INVENTORY ............................................................................................................................. 29 C. GREENHOUSE GAS REPORTING ............................................................................................................................... 29

8. FEE PAYMENT .............................................................................................................................................. 29

9. GENERAL CONDITIONS ................................................................................................................................ 29

A. TERM ................................................................................................................................................................ 29 B. BASIC OBLIGATION .............................................................................................................................................. 30 C. DUTY TO SUPPLEMENT APPLICATION ....................................................................................................................... 30 D. RIGHT TO ENTER ................................................................................................................................................. 30 E. TRANSFER OF OWNERSHIP .................................................................................................................................... 31 F. POSTING OF PERMIT ............................................................................................................................................ 31



G. PERMIT REVOCATION FOR CAUSE ........................................................................................................................... 31 H. CERTIFICATION OF TRUTH, ACCURACY, AND COMPLETENESS ........................................................................................ 31 I. EXPIRATION AND RENEWAL OF PERMIT .................................................................................................................... 31 J. SEVERABILITY ...................................................................................................................................................... 32 K. PERMIT SHIELD ................................................................................................................................................... 32 L. PERMIT REVISIONS ............................................................................................................................................... 32 M. PERMIT RE-OPENING ....................................................................................................................................... 33 N. RECORD RETENTION ............................................................................................................................................. 34 O. SCOPE OF LICENSE CONFERRED .............................................................................................................................. 34 P. EXCESS EMISSION REPORTS; EMERGENCY PROVISION ................................................................................................. 34

10. ADDITIONAL PROVISIONS APPLICABLE TO TITLE V SOURCES ................................................................... 36

A. ENFORCEMENT BY THE ADMINISTRATOR AND CITIZENS ............................................................................................... 36 B. FEDERAL ENFORCEABILITY EXCLUSIONS .................................................................................................................... 36

11. EQUIPMENT ............................................................................................................................................ 36

12. INSIGNIFICANT ACTIVITIES ...................................................................................................................... 37

APPENDIX A ......................................................................................................................................................... 39



1. Introduction

This permit renewal pertains to an existing electrical power plant, owned and operated by

Arizona Public Service Company, an Arizona corporation. The SIC Code is 4911. The facility,

commonly known as Sundance Power Plant, is located on 2060 West Sundance Road, Casa

Grande. The source is situated in an area classified as non-attainment for PM10 and attainment

for all other pollutants.

The plant currently includes ten natural gas fired combustion turbine ("CT") with a nominal

rating of 45 mw each. Each CT system has a separate stack. The control configuration includes

water injection followed by selective catalytic reduction (SCR), as well as an oxidation catalyst.

The plant is a "major emitting source" of CO, PM10 and NOx. That status requires that this

permit implement the "Prevention of Significant Deterioration" (PSD) requirements defined in

the Clean Air Act (1990) ("CAA"). See the 2001 TSDs for a discussion of the Best Available

Control Technology (BACT) determination, as well as other PSD-related issues. The source is

also subject to the operating permit requirements under Title V of the CAA. This permit will

provide authority-to-construct under the PSD program, and authority-to-operate under the Title V

program.

For clarification, as required by 40 CFR §70.6(b), all provisions of this permit, other than those

expressly identified in permit section 10.B, are federally enforceable.

The Technical Support Document for this permit includes a permitting history section, as well as

a summary of any applicable requirements updates or changes made during this renewal.

2. Listing of (Federally Enforceable) Applicable Requirements

[Mandated by 40 CFR §70.5a(4)]

A. Those portions of Pinal County Air Quality Control District ("PCAQCD") Regulations

("Code"), as revised by the Pinal County Board of Supervisors on October 12, 1995, and

approved by the Administrator as elements of the Arizona State Implementation Plan

("SIP") at 61 FR 15717 (4/9/96). The following all specifically pertain to the issuance of

this initial permit:

§3-1-040 Applicability and Classes of Permits

§3-1-050 Permit Application Requirements

§3-1-081 Permit Conditions

§3-1-082 Emission Standards and Limitations

§3-1-083 Compliance Provisions

§3-1-103 Annual Emissions Inventory Questionnaire

§3-1-132 Permit imposed right of entry

§3-1-150 Monitoring

§3-1-160 Test Methods and Procedures

§3-1-170 Performance Tests



§3-1-173 Quality Assurance

§3-1-177 Stack Height Limitation

§§3-3-200 through 3-3-210, and 3-3-250 through 3-3-280 - Permit Requirements for New

Major Sources ... [Located in Attainment Areas]

B. Those specific provisions of the Pinal-Gila Counties Air Quality Control District

("PGCAQCD") Regulations, as adopted by the Pinal County Board of Supervisors on

March 31, 1975, and approved by the Administrator as elements of the Arizona State

Implementation Plan ("SIP") at 43 FR 53034 (11/15/78), and specifically the following

rules:

7-3-1.2 Emission Standards - Particulate Emissions - Fugitive Dust

7-3-5.1 NOx Emissions - Fuel Burning Equipment

C. Those specific provisions of the PGCAQCD Regulations, as last amended by the Pinal

County Board of Supervisors on June 16, 1980, and approved by the Administrator as

elements of the Arizona SIP at 47 FR 15581 (4/12/82), specifically, the following rules:

7-3-1.1 Visible Emissions; General

7-3-1.7.F Fuel Burning Equipment

D. The New Source Performance Standards ("NSPS") 40 CFR Part 60, Subpart GG -

Stationary Gas Turbines, §§60.330 - 60.335, Code §6-1-030.39

E. CAA §112(r) (11/15/90); 40 CFR Part 68 (7/31/98); Chemical Accident Prevention

Provisions

F. Acid Rain Provisions; CAA Title IV, and:

40 CFR Part 72 Permit Regulation - Code §3-6-565

40 CFR Part 73 Sulfur Dioxide Allowance System - Code §3-6-565

40 CFR Part 75 Continuous Emission Monitoring (Acid Rain Program) - Code §3-6-565

G. CAA §§608 & 611 (11/15/90); 40 CFR Part 82, Subpart F - Recycling and Emissions

Reduction (9/7/95); regulations pertaining to use and handling of ozone-depleting

substances.

H. Those specific provisions of the PCAQCD Regulations, as last amended by the Pinal

County Board of Supervisors on April 27, 2004, and approved by the Administrator as

elements of the Arizona SIP at 75 FR 17307 (4/6/10), specifically, the following rule:

§4-2-040 Standards (Fugitive Dust Reasonable Precautions)

I. Those specific provisions of the PCAQCD Regulations, as last amended by the Pinal

County Board of Supervisors on May 18, 2005, and approved by the Administrator as

elements of the Arizona SIP at 71 FR 15043 (3/27/06), specifically, the following rule:



§2-8-300 (Opacity) Performance Standards

J. National Emissions Standards for Hazardous Air Pollutants, 40 CFR Part 63, Subpart

ZZZZ, Internal Combustion Engines[40 CFR §63.6080 - 6175].

3. Prospective Compliance Requirements

A. Compliance Plan

[Mandated by 40 CFR §70.(5)(c)(8)] (Code §3-1-083A.7)

Insofar as the Permittee is currently in compliance, the compliance plan consists of

continued adherence to the requirements of this permit and those requirements set forth in

applicable regulations and statutes.

B. Compliance Schedule

[Mandated by 40 CFR §§ 70.5(c)(8), 70.6(c)(3)] (Code §3-1-083.A.7)

Insofar as the Permittee is currently in compliance, no compliance schedule to attain

compliance is required, with the following exception:

1. Risk Management Program and Plan

If the source has more than a threshold quantity of a regulated substance in a

process as determined under 40 CFR 68.115, Permittee shall conform in a timely

manner to requirements applicable to this source under CAA §112(r) and 40 CFR

part 68, including at a minimum:

a. Submittal of a complete risk management plan ("RMP") to the District or

other state or local agency designated by the state for this purpose, by

such deadline as may be established under 40 CFR Part 68. The RMP

submittal shall include a certification that the plan is complete and

accurate;

b. Submittal of any additional information required for completeness;

c. Annual certification of implementation of the risk management program

as described by the RMP.

4. Authority to Construct

[Federally enforceable - Code §§3-1-010, 3-1-040 (as amended 10/12/95) approved as a SIP

Element at 65 FR 79741 (12/20/00)]

Emissions from this facility, specifically the equipment described in "Equipment Schedule"

section below, and the operating configuration as defined below and more fully described in the



application for permit, fall subject to the enforceable limitations identified throughout this permit.

Therefore, based on the regulations in effect upon the date of issuance of this permit and a finding

that allowable emissions from the equipment described in the Equipment Schedule will neither

cause nor contribute to a violation of any ambient air quality standard even without any additional

limitations, this permit constitutes authority to construct and operate such equipment. For

purposes of future revision to the permit for this facility, each of the limitations of this permit

section shall be considered "PSD" limitations.

A. CT System Requirements

(Code §3-3-250.A.1)

1. Each CT unit shall:

a. incorporate a system for the reduction of NOx, which shall consist of a

system for the selective catalytic reduction of NOx, including ammonia

injection and a catalyst system that will meet the operational limitations

of this permit;

b. incorporate a system for the reduction of CO, which shall consist of a

system for the catalytic oxidation of CO that will meet the operational

limitations of this permit;

c. exhaust to the atmosphere through a stack not greater than 10.5' in outlet

diameter, nor less than 85' in height;

d. each stack shall be equipped with such platforms and sampling ports as

may be required to fulfill the testing and monitoring requirements set

forth below;

e. include separate fuel-flow meters for each respective CT.

f. include NOx and CO monitoring systems as defined in the compliance

provisions of this permit.

g. include systems for monitoring and recording the inlet temperature for

each of the turbine units.

2. For each turbine unit, Permittee shall limit the aggregate number of annual

operating hours, including startup and shutdown operations, to no more than

7,500 hours in any rolling 12-month period.

3. Permittee shall limit the number of startup events for each CT unit to no more

than 1,000 such events in any rolling 12-month period.

4. Except for emergencies, the diesel-driven fire pump shall not be operated more

than 100 hours per calendar year.



B. PSD Emission Limits

1. Definitions

a. “Start-up” is defined as the 15-minute period following the indication of

a Unit On signal.

b. "Warm-up" is defined as the 24-minute period following "start-up."

c. “Shutdown” is defined as the period beginning with the indication of the

Shutdown signal and ending with the Unit Off signal.

d. “Malfunction” is defined as any sudden and unavoidable failure of air

pollution control equipment, process equipment or a process to operate in

a normal and usual manner, but does not include failures that are caused

by poor maintenance, careless operation or any other upset condition or

equipment breakdown which could have been prevented by the exercise

of reasonable care.

2. Emission Limitations and Associated Requirements

(Code §3-3-250.)

a. CT Emission Rate Limitations

Other than during periods of start-up, warm-up, shut-down, and

malfunction, Permittee shall not cause to be discharged into the

atmosphere from any of the gas turbine systems during CT operations

any gases which:

1. contain nitrogen oxides emissions in excess of 5.0 ppmvd

corrected to 15 percent oxygen, based on a rolling, accumulating

3-operating hour average.

2. contain carbon monoxide emissions in excess of any of the

following temperature-specific concentration limitations, based

on correction to 15% oxygen, and a rolling, accumulating 3-

operating hour average:

i. 15.0 ppmvd below 59̊ F.; and

ii. 7.5 ppmvd at or above 59̊ F.

3. contain PM10 emissions in excess of 7.0 lbs/hr.;

4. contain VOC emissions in excess of 4.5 lbs/hr.;



5. exhibit opacity in excess of 40%, as measured by Method 9.

b. CT Start-up and Warm-up Limitations and Requirements

1. During start-ups of the CT units, the Permittee shall be exempt

from any limitations on emission of NOx, but Permittee shall

exercise "good combustion practice," consisting of adherence to

standard operating procedure.

2. During warm-ups of the CT units, Permittee shall limit the

average NOx emissions to 25 ppmvd @ 15% O2 as determined by

an average of 24 minutes of warm-up emissions data.

Substituted data should not be used to determine compliance

with this limit.

3. For emission inventory purposes, Permittee shall use the

following emissions during a combined start-up and warm-up

event:

A. NOx – 18.61 lbs

B. CO – 7.36 lbs

C. VOC – 1.73 lbs

c. CT Shutdown Limitations and Requirements

1. During shutdown of the CT units, the Permittee shall be exempt

from any limitations on emission of NOx, but Permittee shall

exercise "good combustion practice," consisting of adherence to

standard operating procedure.

2. For emission inventory purposes, Permittee shall use the

following emissions during a shutdown event:

A. NOx – 2.57 lbs

B. CO – 0.07 lbs

C. VOC – 0.08 lbs

3. If a CT unit shuts down within the 24-minute period immediately

following termination of the start-up period, and the conditions

of permit condition 4.B.1.c. have been met, the unit shall comply

with the requirements of this permit condition 4.B.2.c.

d. Minimum Operating Load



Other than during startup, warmup or shutdown or as a result of upset or

malfunction, Permittee shall not operate each of the CT units below a

minimum of 32% of baseload capacity (approximately 15 mW), based on

a 12-month rolling average.

e. Good Operating Practice

At all times, Permittee shall operate the CT units in accordance with the

manufacturer's specifications in order to minimize emissions of

particulate matter, carbon monoxide, and volatile organic compounds.

Permittee may transcribe those manufacturer's specifications into

standard operating procedures to be utilized by on-site staff.

C. Fuel Use Limitations

(Code §3-1-081.)

1. CT Fuels

(Code §3-3-250.A.1)

See permit condition §5.C.1.b

2. Diesel Driven Fire Pump

(Code §5-23-1020)

In the diesel driven fire pump, Permittee shall not burn diesel fuel having a sulfur

content exceeding 500 ppmw.

D. Timing and Progress of Construction

(Code §3-3-210.4)

This permit shall be subject to termination if the proposed construction on the first phase

(up to ten turbines) has not begun within 18 months of permit issuance, or if during the

construction work for the first phase is suspended for more than 18 months. The second

phase of construction for turbines authorized by this permit may commence at any time

during the term of this permit. However, for any turbine units that are not under

construction within 18 months of the issuance of this permit, then prior to commencing

construction on that second phase, the Permittee will need to first obtain a prior

significant revision to this permit in order to revisit the BACT determination for those

additional turbines.

5. Emission Limitations and Controls

[Mandated by 40 CFR §70.6(a)(1)]

A. Applicable Limitations

(Code §3-1-082)



Where different standards or limitations apply under this permit, the most stringent

combination shall prevail and be enforceable.

B. Allowable Emissions

(Code § 3-1-081.A.2.)

Permittee is authorized to discharge or cause to discharge into the atmosphere those

emissions of air contaminants as set forth in Sections 3, 4 and 5 of this permit. Unless

exempted as an insignificant activity under Code §1-3-140.79a, as a categorical

exemption under Code §3-1-040.C., or authorized by a separate permit or by a revision or

operational change allowed under this permit or under Chapter 3, Article 2 of the Code,

Permittee shall not commence construction of, operate or make any modification to this

source in a manner which will cause emissions of any regulated air pollutant in excess of

the 5.5lbs/day de minimis amount defined in Code §1-3-140.37.

C. Emission Limits

1. NSPS Subpart GG Limitations

[40 CFR 60.332 & 60.333] Code §6-1-030.

a. Permittee shall not cause to be discharged into the atmosphere from the

gas turbines any gases which contain nitrogen oxides in excess of:

STD = 0.0075(14.4)/Y

where STD = NOx emissions (% by volume at 15% oxygen and

on a dry basis)1

Y = rated heat load (kilojoules per watt) (not greater than 14.4)

b. In the CT units, Permittee is allowed to burn exclusively pipeline natural

gas, provided Permittee shall not burn natural gas having a hydrogen

sulfide content in excess of 1 grain 100 scf, or a total sulfur content in

excess of 20 grains/100 scf. For compliance reporting and emission

inventory purposes, permittee shall quantify SO2 emissions using an SO2

emission rate of 0.0006 lbs/mmBtu.

2. NESHAP Limitations on Emergency Compression Ignition Engines

<500 hp constructed before June 12, 2006 and located at minor sources of HAP

[40 CFR §§63.6595, 63.6603, 63.6605]

1 The turbines are rated at 446 mmBtu/hr (HHV) each; that mathematically reduces to an allowable NOx emission rate of

0.0075 percent by volume, or 75 ppmvd.



Permittee shall comply with the limitations of Table 2d of 40 CFR Part 63,

Subpart ZZZZ no later than May 3, 2013.

Except during periods of startup, Permittee shall:

a. Change oil and filter or pass the oil analysis set forth in permit condition

§6.C.4 every 500 hours of operation or annually, whichever comes first;

b. Inspect air cleaner every 1,000 hours of operation or annually, whichever

comes first;

c. Inspect all hoses and belts every 500 hours of operation or annually,

whichever comes first, and replace as necessary.

D. Fuel-Burning Equipment - Particulate Emissions

1. SIP Limitation

[Currently federally enforceable pursuant to PGAQCD Reg. 7-3-1.7 (3/31/75)

approved as a SIP element at 43 FR 50531 (11/15/78)]

For equipment with a heat input capacity of less than 4,000 million Btu per hour,

particulate emissions shall not exceed2:

E = 1.02X-.231, where E = maximum emissions in lbs./hr. for each million BTU

per hour heat input, and X = maximum heat input capacity in million BTU per

hour.

2. Current Code Limitation

(§5-23-1010)

For equipment with a heat input capacity of less than 4,200 million Btu per hour,

particulate emissions shall not exceed3:

E = 1.02Q0.769, where E = maximum emissions in lbs./hr. for each million BTU

per hour heat input, and Q = maximum heat input capacity in million BTU per

hour.

E. Particulate Emissions - Control of Fugitive Dust

2 The turbines are rated at 446 mmBtu/hr (HHV) each, and that mathematically reduces to an allowable

PM emission rate of 111.16 lb/hr.

3 The turbines are rated at 446 mmBtu/hr (HHV) each, and that mathematically reduces to an allowable

PM emission rate of 111.16lb/hr.



[Currently federally enforceable pursuant to PGAQCD Reg. 7-3-1.2 (3/31/75) approved

as a SIP element at 43 FR 50531 (11/15/78)] (Code §§2-8-300. and 4-2-040.)

1. Permittee shall not cause, suffer, allow or permit a building or its appurtenances

or open area to be used, constructed, repaired, altered or demolished without

taking reasonable precautions to prevent particulate matter from becoming

airborne. Particulate emissions shall be kept to a minimum by such measures as

wetting down, covering, landscaping, paving, treating or by other reasonable

means.

2. Permittee shall not cause, suffer, allow or permit the repair, construction or

reconstruction of a roadway or alley without taking reasonable precautions to

prevent particulate matter from becoming airborne dust and other particulates

shall be kept to a minimum by employing temporary paving, dust palliatives,

wetting down, detouring or by other reasonable means. Earth or other material

shall be removed from paved streets onto which earth or other material has been

transported by trucking or earth moving equipment, erosion by water or by other

means.

F. Generally Applicable Opacity Limits

1. SIP Limitation

[Currently federally enforceable pursuant to PGAQCD Reg. 7-3-1.1 (6/16/80)

approved as a SIP element at 47 FR 15579 (4/12/82)]

The opacity of any plume or effluent shall not be greater than 40 percent as

determined by Reference Method 9 in the Arizona Testing Manual (ADEQ,

1992). Nothing in this limitation shall be interpreted to prevent the discharge or

emission of uncontaminated aqueous steam, or uncombined water vapor, to the

open air.

2. Visibility Limiting Standard

[Federally enforceable pursuant to Code §2-8-300 (5/18/05) approved as a SIP

element at 71 FR 15043 (3/27/06)]

The opacity of any plume or effluent from any point source not subject to a New

Source Performance Standard adopted under Chapter 6 of the Code, and not

subject to an opacity standard in Chapter 5 of the Code, shall not be greater than

20% as determined in Method 9 in 40 CFR 60, Appendix A.

3. Code Limitation ROTATING EQUIPMENT ONLY

(Code §5-23-1010)

Permittee shall limit the opacity of emissions from any stationary rotating

machinery, excluding the emergency fire pump, such that opacity does not



exceed 40% for longer than 10 consecutive seconds. Visible emissions when

starting cold equipment shall be exempt from the requirement of this

subparagraph for the first 10 minutes of operation.

G. Reasonable Precautions

[Currently federally enforceable pursuant to PCAQCD Reg. 4-2-040 (6/29/93)

approved as a SIP element at 72 FR 41896]

1. Permittee shall not cause, suffer, allow, or permit a building or its appurtenances,

subdivision site, driveway, parking area, vacant lot or sales lot, or an urban or

suburban open area to be constructed, used, altered, repaired, demolished,

cleared, or leveled, or the earth to be moved or excavated, or fill dirt to be

deposited, without taking reasonable precautions to effectively prevent fugitive

dust from becoming airborne.

2. Permittee shall not cause, suffer, allow, or permit a vacant lot, or an urban or

suburban open area, to be driven over or used by motor vehicles, such as but not

limited to all-terrain vehicles, trucks, cars, cycles, bikes, or buggies, without

taking reasonable precautions to effectively prevent fugitive dust from becoming

airborne.

3. Permittee shall not disturb or remove soil or natural cover from any area without

taking reasonable precautions to effectively prevent fugitive dust from becoming

airborne.

4. Permittee shall not cause, suffer, allow or permit transportation of materials

likely to give rise to fugitive dust without taking reasonable precautions to

prevent fugitive dust from becoming airborne. Earth and other material that is

tracked out or transported by trucking and earth moving equipment on paved

streets shall be removed by the party or person responsible for such deposits.

5. Permittee shall not cause, suffer, allow or permit the use, repair, construction or

reconstruction of any road or alley without taking every reasonable precaution to

effectively prevent fugitive dust from becoming airborne.

H. Surface Stabilization

[Code §4-1-030, adopted 10/28/15, effective 1/1/16]

1. Permittee shall not cause or allow visible fugitive dust emissions from open areas

/ vacant lots (areas not currently utilized for an activity) to exceed 20% opacity

based on EPA Method 9 or the continuous plume or intermittent plume methods

listed in PCAQCD Code §4-9-340.

2. Permittee shall erect barriers or no trespassing signs upon evidence of trespass on

open areas / vacant lots.



3. Permittee shall stabilize any open area / vacant lot greater than 1.0 acre that has

0.5 acre or more of disturbed surface and sign up for the Pinal County Dust

Control forecast within 30 days of discovery. The open area / vacant lot shall be

stabilized the day leading up to and the day that is forecast to be high risk for

dust emissions.

4. Permittee shall not remove vegetation from open areas / vacant lots without

applying dust suppressants before and during the weed abatement. Trackout onto

paved surfaces must be prevented or eliminated and dust suppressants must be

applied following weed abatement to stabilize the entire surface.

5. Stabilization of open areas / vacant lots is determined by the drop ball, threshold

friction velocity, flat vegetation or standing vegetation methods listed in

PCAQCD Code 4-9-320.

6. Permittee shall not cause or allow visible fugitive dust emissions from unpaved

lots (areas being utilized for an activity) greater than 5000 square feet to exceed

20% opacity based on EPA Method 9 or the continuous plume or intermittent

plume methods listed in PCAQCD Code §4-9-340.

7. Permittee shall not allow silt loading equal to or greater than 0.33 oz/ft2 or allow

the silt content to exceed 8% on unpaved lots greater than 5000 square feet.

8. Permittee shall stabilize unpaved lots greater than 5000 square feet by paving,

applying a dust suppressant or graveling.

9. Permittee shall clean up trackout on a paved public roadway that exceeds 50 feet

within 24 hours of discovery and limit opacity to 20% or less while using a rotary

brush or broom.

10. Permittee shall make a record of the control measures applied.

I. Additional Plant-Wide Requirements

1. Sandblasting - Plant Wide

(Code §5-4-160.)

Permittee shall use at least one of the following control measures during

sandblasting operations:

a. Vacuum collection system.

b. Confined blasting.



c. Wet abrasive blasting.

d. Hydroblasting.

e. A control measure that is determined by the Control Officer to be equally

effective to control particulate matter emissions.

2. Architectural Coatings

(Code §5-12-370)

Permittee shall not employ, apply, evaporate or dry any architectural coating, as

defined in §5-12-370.C, for industrial or commercial purposes, material

containing photochemically reactive solvent as defined in §5-9-280 or shall thin

or dilute any architectural coating with a photochemically reactive solvent.

3. Other Spray Painting

(Code §5-13-390)

Permittee shall conduct spray painting operations except architectural coatings in

an enclosed area designed to contain not less than 96% by weight of the

overspray. An enclosed area means a 3-sided structure with walls a minimum of

8 feet high.

4. Disposal

(Codes §$5-12-370 and 5-13-390)

Permittee shall not, during any one day, dispose of a total of more than one and

one-half gallons of any photochemically reactive solvent or of any material

containing more than one and one-half gallons of any such photochemically

reactive solvent by any means which will permit the evaporation of such solvent

into the atmosphere.

5. Cutback and Emulsified Asphalt

(Code §5-16-670)

Except as exempted in §5-16-680, Permittee:

a. Shall not use or apply the following materials for paving, construction or

maintenance:

i. Rapid cure cutback asphalt;

ii. Any cutback asphalt material, road oils or tar which contains

more than 1.5% by volume VOCs which evaporate at 500̊F or



less using ASTM Test Method D-402-76 or more than 27% by

volume total solvent in the asphalt binder.

iii. Any emulsified asphalt or emulsified tar containing more than

3% by volume VOCs which evaporate at 500̊F or less using

ASTM Test Method D-244-89.

b. Shall not store within Pinal County any emulsified or cutback asphalt

product which contains more than 1.5% by volume solvent-VOC unless

such material lot included a designation of solvent-VOCcontent on data

sheet(s) expressed in percent solvent-VOC by volume.

6. Solvent Cleaning

(§5-15-620)

a. Solvent cleaners/degreasers shall:

i. Provide a leak-free container for solvents and articles being

cleaned;

ii. Except for a remote reservoir cleaner using unheated solvent, be

equipped with a cover which prevents the solvent from

evaporating when not processing work;

iii. Be equipped with a drain configured to return solvent drained

from cleaned parts to the container;

iv. Be clearly labeled to identify the solvent and explain the proper

operation of the cleaner;

v. A degreaser/cleaner with a remote reservoir shall be equipped

with a sink-like work area sloped sufficiently toward a drain so

as to prevent pooling of the solvent, a drain from the sink to the

reservoir, with a maximum drain area of 15.5 in2, and unless a

low-volatility solvent with a boiling point above 248̊ f is utilized

and the solvent is never heated above 120̊ f., a stopper shall be

used to seal the drain opening or a cover placed over the sink

when the device is not in use.

vi. For a degreaser/cleaner without a remote reservoir, if the

degreaser utilizes a low-volatility solvent with a boiling point

above 248̊ f., and the solvent is not agitated in use, Permittee

shall maintain a minimum 6" freeboard and keep the cover

closed when the apparatus is not in use; or if using solvents

which are not low volatility or which are agitated or are heated

above 120̊ F shall have internal drainage and a freeboard ratio of

0.75 or greater; or a water cover may be used to meet the

freeboard requirement if the solvent is insoluble in and denser

than water; and a cover shall be used that is of a sliding or rolling

type which is designed to easily open and close without

disturbing the vapor zone. The degreaser/cleaner shall be



equipped with a clear and conspicuous mark for the maximum

allowable solvent level; and as an alternative to the foregoing

freeboard requirement, be equipped with a hood or enclosure

with a ventilation rate of no less than 65 cfm per ft.2 of

evaporative surface, unless a more stringent requirement applies

pursuant to OSHA requirements, and the overall control

efficiency of emissions from the cleaner, considering both

capture and destruction, shall not be less than 85%.

b. Permittee shall operate the cold solvent cleaners/degreasers in

accordance with the operating requirements listed in Code §5-15-620.H.

Each cold solvent/degreaser shall have a permanent, conspicuous label

which summarizes the relevant operating requirements.

J. General Maintenance Obligation

[40 CFR 60.11(d), A.R.S. §49-514(J), Code §§3-1-081.E., 8-1-030.A.3]

At all times, including periods of start-up, shutdown, and malfunction, owners and

operators shall, to the extent practicable, maintain and operate the permitted facility

including associated air pollution control and monitoring equipment in a manner

consistent with good air pollution control practice for minimizing emissions.

K. Generally Applicable Limits

1. Asbestos NESHAP Compliance

[Currently federally enforceable; 40 CFR Part 61, Subpart M] (Code §§7-1-

030, 7-1-060)

Permittee shall comply with Code §§7-1-030.A. and 7-1-060 and 40 CFR Part

61, Subpart M, when conducting any renovation or demolition activities at the

facility.

2. Stratospheric Ozone and Climate Protection

[Currently federally enforceable; 40 CFR Part 82 Subpart F]

The permittee shall comply with the standards for recycling and emissions

reduction pursuant to 40 CFR Part 82, Subpart F, Recycling and Emissions

Reduction.

L. Acid Rain Requirements

(Code §§3-6-565, 3-1-081.A.6)

1. When provisions or requirements of the regulations incorporated pursuant to

Code §3-6-565 (i.e. the Acid Rain Program) conflict with any of the other

applicable requirements set forth in this permit, the regulations incorporated

under §3-6-565 shall apply and take precedence.



2. No permit revision shall be required for increases in emissions that are authorized

by allowances acquired pursuant to the Acid Rain Program, provided that such

increases do not require a permit revision under any other applicable

requirement. Code §3-1-081.A.6.a.

3. No limit shall be placed on the number of allowances held by the source. The

source may not, however, use allowances as a defense to noncompliance with

any other applicable requirement. Code §3-1-081.A.6.b.

4. Any such allowance shall be accounted for according to the procedures

established in regulations promulgated under Part IV of the CAA, commonly

known as CAA Title IV. Code §3-1-081.A.6.c.

5. All of the following are prohibited: (Code §3-1-081.A.6.d.)

a. Annual emissions of sulfur dioxide in excess of the number of

allowances to emit sulfur dioxide held by the owners or operators of the

unit or the designated representative of the owners or operators.

b. Exceedances of applicable emission rates specified in this permit.

c. The use of any allowance prior to the year for which it was allocated.

d. Contravention of any other provision of this permit.

M. Emergency Risk Management and Emergency Response Plan Requirements

1. Chemical Accident Prevention Requirements

[Currently federally enforceable; 40 CFR Part 68]

If the facility is subject to 40 CFR Part 68 by having more than a threshold

quantity of ammonia, the permittee shall comply with the planning requirements

set forth in 40 CFR Part 68 with regard to the ammonia-handling and ammonia-

storage at the facility, as well as any other process or facility affected under 40

CFR Part 68, including:

a. Submittal of a compliance schedule as required under 40 CFR Part 68,

by the date required under 40 CFR §68.10(a); or

b. As part of the compliance certification submitted under 40 CFR

§70.6(c)(5), a certification statement that the source is in compliance

with all requirements of 40 CFR Part 68, including the registration and

submission of a release management plan.

6. Compliance Demonstration

A. Testing




1. Performance Test Methodology

(Code §3-1-160.D) [Currently federally enforceable pursuant to PCAQCD

Code 3-1-160 (11/03/93) approved as a SIP element at 65 FR 79742]

Except for ambient air monitoring and emissions testing required under a NSPS

or NESHAP, alternate sampling techniques or other means to determine opacity,

rate, composition, and/or concentration of emissions in any test plan submitted to

the Control Officer may be approved by the Control Officer for the duration of

that plan provided that the following four criteria are met:

a. The alternative or equivalent test method measures the same chemical

and physical characteristics as the test method it is intended to replace.

b. The alternative or equivalent test method has substantially the same or

better reliability, accuracy, and precision as the test method it is intended

to replace.

c. Applicable quality assurance procedures are followed in accordance with

the Arizona Testing Manual, 40 CFR Part 60 or other methods approved

by the Control Officer.

d. This approval does not include nondelegable functions of the EPA

Administrator, including but not limited to approval of alternative or

equivalent test methods. As used in 40 C.F.R. 60: "Administrator" means

the Control Officer of the Pinal County Air Quality Control District,

except that the Control Officer shall not be authorized to approve

alternate or equivalent test methods, alternative work standards or work

practices, equivalency determinations or innovative technology waivers

as covered in Section 111(h) "Design, equipment, work practice, or

operational standard, alternative emission limitation," and Section 111(k)

"Innovative technological systems of continuous emission reduction" of

the FCAA."

2. Performance Test Methods

[40 CFR 60.8, Code §§3-1-160 & 3-1-170)

At such times as defined below, the owner or operator shall conduct

performance tests and shall furnish the Control Officer a written report of the

results of the tests as provided below. Permittee shall conduct performance tests,

using standard test methods specified below, or equivalent methods as approved

by the District pursuant to approval of the test plan required below. The tests

shall be conducted using standard test methods approved by the EPA (40 CFR

Part 60). These tests shall be performed at the maximum practical production

rate. A test plan protocol for each test shall be submitted to the District at least

thirty (30) days before the testing. The continuous monitoring systems required



by this permit shall be in place and operating prior to conducting the performance

tests.

a. nitrogen oxides emissions Ref. Part 60, App. A, Ref. Method 7e or

subsidiary method

b. carbon monoxide emissions Ref. Part 60, App. A, Ref. Method 10

c. particulate matter emissions (filterable PM10) Ref. Part 60, App. A, Ref.

Method 5 or 201A and (condensable PM10) Method 202

d. volatile organic compound emissions Ref. Part 60, App. A, Ref. Method

25a

e. opacity Ref. Part 60, App. A, Ref. Method 9, 40 CFR §60.11

3. Performance Testing Schedule

(Code §3-1-050)4

In addition to the monitoring requirements pertaining to NOx and CO listed in

Subsection B. below, at least once during the year 2012 and during every

subsequent 5-year permit term, Permittee shall conduct recurring performance

tests for VOCs and PM10 using the test methods listed above. Two CTs may be

selected for testing and used to represent all of the identical CTs at the facility to

meet this requirement and used for emissions calculations and emissions

inventory. Selection of the two CTs used shall be rotated for each subsequent

testing.

4. Test Protocol

A test plan protocol for each test shall be submitted to the District for approval at

least thirty (30) days before the testing. The protocol shall specifically identify

which CTs are to be tested for compliance demonstration.

5. Performance Test Notices

Notice of any performance test required by this permit shall be submitted to the

District at least five days prior to running the test.

6. Test Reports

A copy of each test report shall be submitted to the District for approval within

forty-five days after the test. In addition to any other information required under

this permit, the Test Report for all mandatory tests shall specifically define:

4

The initial Title V permit for this facility did not require recurring testing for VOC and PM10 and therefore the testing data used for purposes of

emissions calculations and emissions inventory dates back to 2002. In order to obtain more current data, PCAQCD has added a recurring

schedule for these pollutants as part of this renewal, which will also make this permit’s testing schedule consistent with other electric utility

permits.



a. NOx emissions rates, defined as both as a function of heat input, and

expressed in the same units as the NOx emission limitations imposed

under this permit.

b. CO emissions rates, defined as both as a function of heat input, and

expressed in the same units as the CO emission limitations imposed

under this permit.

c. VOC emissions rates, defined both as a function of heat input, and

expressed in the same units as the VOC emission limitations imposed

under this permit.

d. PM10 emission rates, defined both as a function of heat input, and

expressed in the same units as the PM10 emission limitations imposed

under this permit.

B. Monitoring


1. Instrumental emissions monitoring - oxides of nitrogen

[40 CFR 60.334(b), Code §3-3-260.G.]

Permittee shall install, calibrate, maintain, and operate a continuous monitoring

system, and record the output of the system, for measuring:

a. nitrogen oxides emissions from the CT discharged to the atmosphere.

b. either the oxygen or carbon dioxide content of flue gas from each of the

CT units, with the measurement taken where the NOx emissions are

monitored.

c. Monitoring equipment required under this permit subsection shall be

installed, operated, and quality assured in accordance with the

requirements of 40 CFR Part 75.

Permittee shall conduct NOx CEMs evaluations in accord with the RAA

and RATA requirements for NOx CEMs, under 40 CFR Part 75,

Appendix A. Evaluations shall be conducted at least annually unless the

unit qualifies for an extension under 40 CFR Part 75, Appendix B. The

deadline for the next RATA shall be no more than 8 calendar quarters

after the quarter in which a RATA was last performed. A 720 operating

hour grace period is available if the RATA cannot be completed by the

deadline.

2. Instrumental emissions monitoring - Carbon monoxide

[Code §3-3-260.G.]



a. Monitoring equipment required under this subsection shall be installed

and operated pursuant to a plan submitted to the District by the permittee

at least 60 days prior to the initial performance tests required under the

initial permit.

b. On each CT unit, Permittee shall install, calibrate, maintain, and operate

a continuous monitoring system, and record the output of the system, for

measuring carbon monoxide emissions to the atmosphere. Permittee

shall use the quality assurance provisions of 40 CFR Part 75 for the CO

monitoring systems with the exception that a quarterly Cylinder Gas

Audit (CGA) in accordance with 40 CFR Part 60 shall be conducted

every calendar quarter regardless of the instrument span. A CGA will

not be required on quarters in which a RATA is performed.

Permittee shall conduct CO CEMs evaluations in accord with 40 CFR

Part 60 Appendix B, Performance Specification 4. RATA evaluations

shall be conducted at least annually unless the unit qualifies for an

extension under 40 CFR Part 75, Appendix B. The deadline for the next

RATA shall be no more than 8 calendar quarters after the quarter in

which a RATA was last performed. A 720 operating hour grace period is

available if the RATA cannot be completed by the deadline.

c. On each CT unit, Permittee shall install, calibrate, maintain, and operate

a continuous inlet air temperature monitoring system, and shall record

the output of the system. The plan shall require inlet temperature

monitoring and data recording on consistent with the monitoring

requirements of 40 CFR 60.

3. General parametric emission monitoring requirements

[Code §3-3-260.G]

To provide a basis for the other aspects of parametric monitoring set forth below,

Permittee shall maintain operating logs detailing:

a. hours of operation for each CT unit, defining periods of normal operation

of CT operation, start-up periods, warm-up periods, and shut-down

periods.

b. fuel flow/heat input to the CT units, separately defining fuel flow/heat

input during the various system operating modes, including during

startups, warm-up periods, normal operation of the CT units, and during

shutdown.

c. To verify compliance with the operational limitations on the diesel-

driven fire pump, Permittee shall maintain a log reflecting hours of both

emergency and non-emergency operation. The log shall further include a



narrative explanation of the nature of any "emergency" that required

emergency use of the fire pump.

4. Parametric emissions monitoring - Volatile organic compounds

[Code §3-3-260.G.]

As a surrogate for monitoring actual emissions, Permittee shall periodically

calculate the quantity of VOC emissions on a basis adequate to comply with the

reporting requirements under this permit, by multiplying the aggregate fuel

flows/heat input by the corresponding VOC emission factors defined in an

approved performance test, or otherwise defined in this permit.

5. Parametric Emissions monitoring - Particulate matter

[Code §3-3-260.G.]

a. As a surrogate for monitoring actual PM10 emissions, Permittee shall

periodically calculate the quantity of PM10 emissions, by multiplying the

aggregate fuel flows/heat input by the corresponding PM10 emission

factors defined in an approved performance test, or otherwise defined in

this permit.

b. On at least a semi-annual basis during operations, Permittee shall

conduct a visual opacity screen performed on each stack. If visible

emission are observed, Permittee shall have a full Method 9 opacity test

performed by a certified opacity observer, and shall provide a copy of the

resulting report to the District within 10 days.

6. Parametric emissions monitoring - sulfur dioxide

[Code §3-3-260.G.]

As a surrogate measurement for monitoring emissions of sulfur dioxide,

Permittee shall maintain monthly records reflecting total fuel consumption in

each CT unit. On a cycle adequate to comply with the emission limitations and

quarterly reporting requirements under this permit, Permittee shall utilize the SO2

emission calculation methodology set forth in 40 CFR part 75, Appendix D §2.3,

to calculate and report SO2 emissions. Permittee shall determine fuel sulfur

content by either:

a. Maintaining a contractual commitment with the pipeline gas supplier

demonstrating that the gas has a hydrogen sulfide content of 1 grain/100

scf or less, and a total sulfur content of 20 grain/100 scf or less; or

b. At least annually, sampling and analyzing the composition of the

pipeline gas to show whether the gas has a hydrogen sulfide content of 1

grain/100 scf or less, and a total sulfur content of 20 grain/100 scf or less.



7. Periodic monitoring - Emergency Fire Pump Fuel Sulfur Content.

As a surrogate measurement for quantifying the sulfur content in diesel fuel for

the emergency fire pump, Permittee shall maintain a contractual commitment

with or a certification from the Permittee's fuel supplier, showing that only diesel

fuel qualified for on-highway use is being delivered to the fire pump, which shall

constitute a demonstration of compliance with the 500 ppmw sulfur content

limitation defined above.

8. Parametric emission monitoring - Minimum Load Operation

[Code §3-3-260.G.]

Permittee shall maintain a 12 month rolling average showing the total power

produced for each individual turbine, and the number of operating hours for that

turbine unit. If permittee elects to also log startup and shutdown events,

permittee may correspondingly deduct cold start and shutdown times as defined

above for each such start/stop cycle for purposes of tabulating the annual

operating hours for that unit. The resulting product of the power produced for

each unit divided by the adjusted number of operating hours shall show that the

unit operated at least 32% of baseload capacity.

9. Parametric emission monitoring - General Maintenance

[Code §3-3-260.G.]

To assure compliance with the general maintenance obligation defined under this

permit, Permittee shall maintain repair logs with regard to each CT, and each

catalytic reactor unit.

10. Parametric emission monitoring - Operating Cycle

[Code §3-3-260.G.]

Permittee shall maintain a 12 month rolling average showing the total number of

operating hours, including startup and shutdown, for each individual turbine.

11. Parametric emission monitoring - Startup Events

[Code §3-3-260.G.]

Permittee shall maintain a 12 month rolling average showing the total number of

startup events for each individual turbine.

C. NESHAP Monitoring and Compliance for Emergency Compression Ignition Engines

[40 CFR §§63.6625(e), (f), (h), (i), 63.6640(f)]

1. Permittee shall maintain the engine according to the manufacturer’s emission-

related written instructions or develop your own maintenance plan which must

provide to the extent practicable for the maintenance and operation of the engine



in a manner consistent with good air pollution control practice for minimizing

emissions.

2. Permittee shall install a non-resettable hour meter if one is not already installed.

3. Permittee shall minimize the engine’s time spent at idle during startup and

minimize the engine’s startup time to a period needed for appropriate and safe

loading of the engine, not to exceed 30 minutes, after which time the non-startup

limitations of Tables 1a, 2a, 2c, and 2d to Subpart ZZZZ apply. of this permit

apply.

4. Permittee has the option of utilizing an oil analysis program in order to extend

the specified oil change requirements of this permit. The oil analysis shall be

performed at the same frequency specified for changing the oil in Section §5.C.2

of this permit. The analysis program shall at a minimum analyze the following 3

parameters: total Base Number, viscosity, and percent water content. The

condemning limits for these parameters are as follows: Total Base Number is less

than 30% of the Total Base Number of the oil when new; viscosity of the oil has

changed by more than 20% from the viscosity of the oil when new; or percent

water content (by volume) is greater than 0.5. If all these limits are not exceeded,

Permittee is not required to change the oil. If any of the limits are exceeded,

Permittee shall change the oil within 2 days of receiving the results of the

analysis, or if not in operation, within 2 days or before commencing operation,

whichever is later. Records of the parameters analyzed, results of the analysis

and oil changes shall be kept. The analysis program shall be part of the

maintenance plan for the engine.

5. Permittee shall not operate the emergency generator other than for emergency

operations, maintenance and testing, and operations in non-emergency situations

for up to 50 hours per year. These 50 hours cannot be used for peak shaving or

to generate income for a facility to supply power to a grid or otherwise supply

power as part of a financial arrangement with another entity, except for 15 hours

per years which may be used as part of a demand response program if the

regional transmission organization has determined there are emergency

conditions that could lead to a potential electrical blackout.

6. Operations during emergency situations is not limited.

7. Permittee may operate the emergency generator for the purpose of maintenance

checks and readiness testing, provided that the tests are recommended by

Federal, State or local government, the manufacturer, the vendor, or the

insurance company associated with the engine. Maintenance checks and

readiness testing is limited to 100 hours per year. The 50 hours of non-

emergency situations allowed in subsection 4 above count towards the 100 hours

for maintenance checks and readiness testing.



D. Recordkeeping

[Mandated by 40 CFR §70.6(a)(3)] [40 CFR §§63.6655(a), (e)](Code §3-1-083)

1. Permittee shall maintain at the source, a file of all measurements, including

continuous monitoring-system-, monitoring-device-, and performance- testing

measurements; all continuous monitoring system performance evaluations; all

continuous monitoring system or monitoring device calibration checks;

adjustments and maintenance performed on these systems or devices; and all

other information required pursuant to any federally enforceable provision of this

permit, recorded in a permanent form suitable for inspection.

2. Permittee shall record the following in a permanent logbook, which may be in

written or digital form, for inclusion in the quarterly report:

a. Emissions of nitrogen oxides, carbon monoxide, particulate matter

(PM10), volatile organic compounds, and sulfur dioxide;

b. Total natural gas burned; and

c. CT run times.

d. The number of start-up and shut-down cycles for each CT unit.

e. For the generator, the records shall specify how many hours were spent

for emergency operations and non-emergency purposes, and if the

generator was used for demand response, the records shall include a

description of the emergency situation, and the time the engine was

operated as part of the demand response.

3. Permittee shall maintain records of the occurrence and duration of any start-up,

shutdown or malfunction in the operation of the permitted facility or any air

pollution control equipment.

4. Recordkeeping of Periodic Facility-Wide Activities (§3-1-081.A.3.b)

Each time an abrasive blasting or spray painting project is conducted, Permittee

shall record the following:

a. Date the project was conducted;

b. Duration of the project;

c. Type of control measures employed; and

d. Material Safety Data Sheets for all paints and solvents used in the

project.



5. Permittee shall keep records of the maintenance conducted on the emergency

generators to demonstrate that they were operated and maintained according to

the maintenance plan or manufacture specification.

E. Compliance Reporting

[Mandated by 40 CFR §§70.6(a)(3) and 70.6(c)(4)] [40 CFR §§63.6640(b), 63.6650(a),

(c), (d)](Code §3-1-083.A)

1. In order to demonstrate compliance with the provisions of this permit, the

Permittee shall submit a quarterly report containing the information required to

be recorded pursuant to this permit. All instances of deviations from permit

requirements shall be clearly identified in such reports. For brevity, such

deviation reports may incorporate by reference any written supplemental upset

reports filed by Permittee during the reporting period. The report shall be

submitted to the District within 30 days after the end of each calendar quarter.

Appendix A of this permit is a form which may be used for the report.

2. With respect to emergency generators, if there are no deviations from any

emissions limitations or operating limitations that apply to the Permittee,

compliance reports after May 3, 2013 shall contain a statement that there were no

deviations from such limitations during the reporting period. If there was a

malfunction, the compliance report shall include the number, duration and brief

description for each malfunction which caused or may have caused any

applicable limitation to be exceeded, as well as a description of the actions taken

to minimize emissions during the malfunction and to correct the malfunction.

F. Regular Compliance/Compliance Progress Certification

[Mandated by 40 CFR §§70.5(c)(8), 70.5(c)(9), 70.6(c)(4), 70.6(c)(5)]

Permittee shall annually submit to the Control Officer, and also to the Administrator of

US EPA a certification of compliance with the provisions of this permit. The

certification shall be separately submitted to both the District and to the Enforcement

Office (AIR 5), EPA Region IX, 75 Hawthorne Street, San Francisco, CA 94105-3901.

The certification shall:

1. Be signed by a responsible official, as defined in 40 CFR 70.2, or such other

person as may be approved by the Control Officer as an administrative

amendment to this permit;

2. Identify each term or condition of the permit that is the basis of the certification;

3. Verify the compliance status with respect to each such term or condition;

4. Verify whether compliance with respect to each such term or condition has been

continuous or intermittent;



5. Identify the permit provision, or other, compliance mechanism upon which the

certification is based; and

6. Be postmarked within thirty (30) days of the start of each calendar year.

7. Other Reporting Obligations

A. Deviation Reporting Requirement

(Code §3-1-083.A.3.b.,§3-1-081.A.5) [Mandated by 40 CFR §§70.6(a)(3)(iii)(B),

70.6(g)]

Permittee shall report any deviation from the requirements of this permit along with the

probable cause for such deviation, and any corrective actions or preventative measures

taken to the District within fifteen days of when the owner or operator first learned of the

deviation unless earlier notification is required by the provisions of Section 9.P. of this

permit.

B. Annual emissions inventory

[Code §§3-1-103, 3-7-590.C.1.]

Permittee shall complete and submit to the District an annual emissions inventory,

disclosing actual emissions for the preceding calendar year. The submittal shall be made

on a form provided by the District. The inventory is due by the latter of March 31, or

ninety (90) days after the form is furnished by the District.

C. Greenhouse Gas Reporting

[40 CFR Part 98]

If this source becomes subject to the provisions of 40 CFR Part 98, then Permittee shall

comply with these provisions accordingly.

8. Fee Payment

[Mandated by 40 CFR §§70.6(a)(7), 70.9]

As an essential term of this permit, an annual permit fee shall be assessed by the District and paid

by Permittee in accord with the provisions of Code Chapter 3, Article 7 generally, and Code §3-1-

081.A.9. specifically. The annual permit fee shall be due on or before the anniversary date of the

issuance of an individual permit, or formal grant of approval to operate under a general permit.

The District will notify the Permittee of the amount to be due, as well as the specific date on

which the fee is due.

9. General Conditions

A. Term

[Mandated by 40 CFR §70.6(a)(2)] (Code §3-1-089)



This permit shall have a term of five (5) years, begining from the date of issuance.

B. Basic Obligation

[Mandated by 40 CFR §§70.4(b)(15), 70.6(a)(6(i), 70.6(a)(6)(ii), 70.7.b] (Code §3-1-

081.)

1. The owner or operator ("Permittee") of the facilities shall operate them in

compliance with all conditions of this permit, the Pinal County Air Quality

Control District ("the District") Code of Regulations ("Code"), and consistent

with all State and Federal laws, statutes, and codes relating to air quality that

apply to these facilities. Any permit noncompliance is grounds for enforcement

action; for a permit termination, revocation and reissuance, or revision; or for

denial of a permit renewal application and may additionally constitute a violation

of the Clean Air Act (1990).

2. All equipment, facilities, and systems used to achieve compliance with the terms

and conditions of this permit shall at all times be maintained and operated in

good working order.

C. Duty to Supplement Application

[Mandated by 40 CFR §§70.5(b), 70.6(a)(6)(v)] (Code §§3-1-050.H, 3-1-081.A.8.e, 3-1-

110)

Even after the issuance of this permit, a Permittee, who as an applicant who failed to

include all relevant facts, or who submitted incorrect information in an application, shall,

upon becoming award of such failure or incorrect submittal, promptly submit a

supplement to the application, correcting such failure or incorrect submittal. In addition,

Permittee shall furnish to the District within thirty days any information that the Control

Officer may request in writing to determine whether cause exists for modifying, revoking

and reissuing, or terminating this permit or to determine compliance with this permit

and/or the Code.

D. Right to Enter

[Mandated by 40 CFR §70.6(c)(2)] (Code § 3-1-132)

Authorized representatives of the District shall, upon presentation of proper credentials,

be allowed:

1. to enter upon the premises where the source is located or in which any records

are required to be kept under the terms and conditions of this permit;

2. to inspect any equipment, operation, or method required in this permit; and

3. to sample emissions from the source.



E. Transfer of Ownership

[Mandated by 40 CFR §70.7(d)(4)]

This permit may be transferred from one person to another by notifying the District at

least 30 days in advance of the transfer. The notice shall contain all the information and

items required by Code § 3-1-090. The transfer may take place if not denied by the

District within 10 days of the receipt of the transfer notification.

F. Posting of Permit

(Code §3-1-100)

Permittee shall firmly affix the permit, an approved facsimile of the permit, or other

approved identification bearing the permit number, upon such building, structure, facility

or installation for which the permit was issued. In the event that such building, structure,

facility or installation is so constructed or operated that the permit cannot be so placed,

the permit shall be mounted so as to be clearly visible in an accessible place within a

reasonable distance of the equipment or maintained readily available at all times on the

operating premises.

G. Permit Revocation for Cause

[Mandated by 40 CFR §70.6(a)(6)(iii)] (Code §3-1-140)

The Director of the District ("Director") may issue a notice of intent to revoke this permit

for cause pursuant to Code §3-1-140, which cause shall include occurrence of any of the

following:

1. The Director has reasonable cause to believe that the permit was obtained by

fraud or material misrepresentation;

2. Permittee failed to disclose a material fact required by the permit application

form or a regulation applicable to the permit;

3. The terms and conditions of the permit have been or are being violated.

H. Certification of Truth, Accuracy, and Completeness

[Mandated by 40 CFR §§70.5(a)(2), 70.6(a)(3)(iii)(B)] [Federally enforceable - Code

§§3-1-083.A.5, 3-1-175 (as amended 2/22/95) approved as SIP Elements at 65 FR

79742 (12/20/00)]

Any application form, report, or compliance certification submitted pursuant to the Code

shall contain certification by a responsible official of truth, accuracy, and completeness.

This certification and any other certification required under Chapter 3 of the Code shall

state that, based on information and belief formed after reasonable inquire, the statements

and information in the document are true, accurate, and complete.

I. Expiration and Renewal of Permit

[Mandated by 40 CFR §§70.5(a)(1)(iii), 70.7(c)](Code §3-1-050.C)



Expiration of this permit will terminate the facility’s right to operate unless either a

timely application for renewal has been submitted in accordance with §§3-1-050, 3-1-055

and 3-1-060, or a substitute application for a general permit under §3-5-490. For Class I

permit renewals, a timely application is one that is submitted at least 6 months, but not

greater than 18 months prior to the date of the permit expiration. For Class II or Class III

permit renewals, a timely application is one that is submitted at least 3 months, but not

greater than 12 months prior to the date of permit expiration.

J. Severability


Pursuant to Code § 3-1-081.A.7., the provisions of this permit are severable, and if any

provision of this permit is held invalid the remainder of this permit shall not be affected

thereby.

K. Permit Shield

[Mandated by 40 CFR §70.6(f)] (Code § 3-1-102.)

Subject to the following schedule of exclusions, compliance with the terms of this permit

shall be deemed compliance with any applicable requirement identified in this permit.

The permit-shield exclusions include:

1. PGCAQCD Rule §7-2-1.8 ANTI-DEGRADATION;

2. Items listed in Section 10 of this permit as not being federally enforceable.

L. Permit Revisions

[Mandated by 40 CFR §70.7(d), 70.7(e)] (Code Chapter 3, Article 2)

1. This permit may be revised, reopened, revoked and reissued, or terminated for

cause. The filing of a request by the permittee for a permit revision, revocation

and reissuance, or termination, or of a notification of planned changes or

anticipated noncompliance does not stay any permit condition.

2. The permittee shall furnish to the Control Officer, within a reasonable time, any

information that the Control officer may request in writing to determine whether

cause exists for revising, revoking and reissuing, or terminating the permit or to

determine compliance with the permit.

3. Permit amendments, permit revisions, and changes made without a permit

revision shall conform to the requirements in Article 2, Chapter 3, of the Code.

4. Revision to Obtain Authority to Reconstruct [Federally enforceable - 40 CFR

63.42(c)] Code §3-1-040.D.



Prior to commencing a reconstruction, as defined below, Permittee shall apply

for and obtain a revision to this permit, which revised permit shall include a final

and effective case-by-case determination pursuant to the provisions of 40 CFR

63.43 such that the emissions from the reconstructed facility will be controlled to

a level no less stringent than the maximum achievable control technology

emission limitation for new sources.

For purposes of this subsection, "reconstruction" is defined as the replacement of

components at an existing process or production unit that in and of itself emits or

has that potential to emit 10 tons per year of any HAP or 25 tons per year of any

combination of HAP, whenever:

a. The fixed capital cost of the new components exceeds 50 percent of the

fixed capital cost that would be required to construct a comparable

process or production unit; and

b. It is technically and economically feasible for the reconstructed major

source to meet the applicable maximum achievable control technology

emission limitation for new sources established under 40 CFR Part 63,

Subpart B.

M. Permit Re-opening

[Mandated by 40 CFR §§70.6(a)(6)(iii), 70.7(g), ] (Code §§ 3-1-050.C.6, 3-1-087.)

1. This permit shall be reopened if:

a. Additional applicable requirements under the Clean Air Act (1990)

become applicable to this source, and on that date, this permit has a

remaining term of three or more years. Provided, that no such reopening

under this subparagraph is required if the effective date of the newly

applicable requirement is later than the date on which this permit is due

to expire, unless the original permit or any of its terms and conditions has

been extended pursuant to Code §3-1-089.C.

b. If the Permittee becomes subject to a standard promulgated by the

Administrator under Section 112(d) of the CAA, the Permittee shall,

within 12 months of the date on which the standard was promulgated,

submit an application for a permit revision demonstrating how the source

will comply with the standard.

b. The Control Officer determines that it contains a material mistake or that

inaccurate statements were made in establishing the emissions standards

or other terms or conditions of it;

c. The Control Officer determines that it needs to be revised or revoked to

assure compliance with the applicable requirements; or



d. The EPA Administrator finds that cause exists to terminate, modify, or

revoke and reissue this permit.

2. If this permit must be reopened or revised, the District will notify the permittee in

accord with Code §3-1-087.A.3.

N. Record Retention

[Mandated by 40 CFR §70.6(a)(3)(ii)(B)] (Code §3-1-083.A.2.b)

Permittee shall retain for a period of five (5) years all documents required under this

permit, including reports, monitoring data, support information, calibration and

maintenance records, and all original recordings or physical records of required

continuous monitoring instrumentation.

O. Scope of License Conferred

[Mandated by 40 CFR §70.6(a)(6)(iv)] (Code §3-1-081.)

This permit does not convey any property rights of any sort, or any exclusive privilege.

P. Excess Emission Reports; Emergency Provision

[Mandated by 40 CFR §70.6(g)] (Code §3-1-081.E, Code §8-1-030)

1. To the extent Permittee may wish to offer a showing in mitigation of any

potential penalty, underlying upset events resulting in excess emissions shall

reported as follows:

a. The permittee shall report to the Control Officer any emissions in excess

of the limits established by this permit. Such report shall be in two parts:

i. Notifications by telephone or facsimile within 24 hours or the

next business day, whichever is later, of the time when the owner

or operator first learned of the occurrence of excess emissions,

including all available information required under subparagraph

b. below.

ii. Detailed written notification within 3 working days of the initial

occurrence containing the information required under

subparagraph b. below.

b. The excess emissions report shall contain the following information:

i. The identity of each stack or other emission point where the

excess emissions occurred.



ii. The magnitude of the excess emissions expressed in the units of

the applicable limitation.

iii. The time and duration or expected duration of the excess

emissions.

iv. The identity of the equipment from which the excess emissions

occurred.

v. The nature and cause of such emissions.

vi. If the excess emissions were the result of a malfunction, steps

taken to remedy the malfunction and the steps taken or planned

to prevent the recurrence of such malfunctions.

vii. The steps that were or are being taken to limit the excess

emissions. To the extent this permit defines procedures

governing operations during periods of start-up or malfunction,

the report shall contain a list of steps taken to comply with this

permit.

viii. To the extent excess emissions are continuous or recurring, the

initial notification shall include an estimate of the time the

excess emissions will continue. Continued excess emissions

beyond the estimated date will require an additional notification.

2. An "emergency" means any situation arising from sudden and reasonably

unforeseeable events beyond the control of the source, including acts of God,

which situation requires immediate corrective action to restore normal operation,

and that causes the source to exceed a technology-based emission limitation

under the permit, due to unavoidable increases in emissions attributable to the

emergency. An emergency shall not include noncompliance to the extent caused

by improperly designed equipment, lack of preventative maintenance, careless or

improper operation, or operator error.

3. An emergency constitutes an affirmative defense to an action brought for

noncompliance with such technology-based emission limitations if the conditions

of the following subparagraph are met.

4. The affirmative defense of emergency shall be demonstrated through properly

signed, contemporaneous operating logs, or other relevant evidence that:

a. An emergency occurred and that the permittee can identify the cause(s)

of the emergency;

b. The permitted facility was at the time being properly operated;



c. During the period of emergency the permittee took all reasonable steps to

minimize levels of emissions that exceeded the emissions standards or

other requirements in the permit; and

d. The permittee submitted notice of the emergency to the Control Officer

by certified mail or hand delivery within 2 working days of the time

when emissions limitations were exceeded due to emergency. The notice

shall contain a description of the emergency, any steps taken to mitigate

emissions, and corrective action taken.

10. Additional provisions applicable to Title V Sources

A. Enforcement by the Administrator and Citizens

[Mandated by 40 CFR §70.6(b)]

All terms and conditions in this permit not excluded in Section 10.B. are enforceable by

the Administrator and citizens under the Clean Air Act.

B. Federal Enforceability Exclusions

[Mandated by 40 CFR §70.6(b)(2)]

To the extent that they are enforceable at all, the following terms and conditions are

enforceable only under authority of State law:

Section 1. - Introduction - This merely constitutes factual background regarding the

facility.

Section 5.D.2 - Fuel Burning Equipment; the cited local rule has not been approved as a

SIP element.

Section 5.F.3 - Opacity; the cited local rule has not been approved as a SIP element.

Section 9.F - Posting of Permit; the cited local rule has not been approved as a SIP

element.

11. Equipment

[Mandated by 40 CFR §70.5(c)(3)(ii)] (Code §3-1-050.B)

Equipment for which emissions are allowed by this permit are as follows:

1. 10 Combustion turbines, General Electric LM6000 SPRINT, natural gas fired, 446

mmbtu/hr each - high heating value, equipped with CEMs, oxidation catalyst and

selective catalytic reduction (SCR).

2. Clean-O-Matic Solvent tank, 85 gal

3. Clarke Fire water pump powered by a John Deere, 183 horsepower, diesel fired engine,

manufactured in October 2001



12. Insignificant Activities

[Mandated by 40 CFR §70.5(c) (Code §3-1-050.E)

Permittee has disclosed the following insignificant activities in the application for this permit:

Emission Point Possible Discharge

Acetylene, Butane, Propane Torches/Cylinders Acetylene, Butane, Propane

Activities Associated with Maintenance Repair or Dismantlement

of an Emission Unit or Other Equipment.

VOC

Aerosol Can Usage VOCs

Ammonia Storage Ammonia Vapor

Barrels/Totes/Bins (Oil Storage Building) - Miscellaneous

Lubricating Oil Storage

Oil Vapors

Brazing and Soldering Activities PM10, Fumes

Cathodic Protection Ozone

Caustic Tank Caustic Vapors

Circuit Breakers Ozone, Oil Vapor

Combustion Turbine Chemicals Chemical Vapors

Combustion Turbine Gas Vents Natural Gas

Combustion Turbine – Lube Oil Vents Oil Vapor

Combustion Turbine – False Start Drains Oil Vapor

Corona Ozone

Electric Motors Ozone

Fuel Oil Storage VOCs

Gas Yard Vents Natural gas

Hydraulic Systems Reservoirs Oil Vapor

Lube Oil Storage Area Oil Vapor

Normal Use of Consumer Products (e.g. cleaning, janitorial,

medical, etc)

CFCs, VOC

Oil Filter Draining Oil Vapor

Pesticide/Herbicide Activity Pesticide, Herbicide

Pump/Motor Oil Reservoirs Oil Vapor

Piping System, Fuel VOCs

Safety Devices, Fire Extinguishers and Cardox System PM10

Septic Tanks – Guard Shack & Admin Building Methane

Battery Banks Acid Vapor

Transformers Oil Vapor

Welding Activities Welding Fumes

Food Processing Equipment PM



Tobacco Smoking Areas PM



Appendix A

Quarterly Report

Permit #V20667.000

Abstract

This constitutes a quarterly report of all required monitoring, documenting emissions during the subject

reporting period.

Reporting Period - Quarter 1st 2nd 3rd 4th Year _________

Facility - Sundance Power Plant

2060 W Sundance Rd

Casa Grande, AZ

Parametric emissions report

Natural gas burned during reporting period mmBtu

Operations report

Power generated during reporting period megawatt-hours

CT Unit #1

"normal" run time hours

Start-up cycles each

CT Unit #2



CT Unit #3



CT Unit #4



CT Unit #5



CT Unit #6



CT Unit #7



CT Unit #8





CT Unit #9



CT Unit #10



Emergency Generator run time (starting May 3, 2013) ............. ______________ emergency hours

__________non-emergency Hours

Was the emergency generator operated and maintained in accordance with the operational

limitations of §5.C.2? ......................................................................................................... YES / NO

Pursuant to §5.H were records of surface stabilization control measures implemented on open

areas/vacant lots and unpaved lots maintained? ............................................................... YES / NO

If required, describe and explain any monitoring activity or recordkeeping that occurred with

respect to the Asbestos NESHAP or Stratospheric Ozone requirements respectively defined in

§§5.K.1 and 5.K.2 of the permit during the reporting period. Is such a supplemental disclosure

attached? ............................................................................................................................ YES / NO

Pursuant to the NOx emission limitation of ¶4.B.2.a.1, did the monitoring records under ¶6.B.1

show continuous compliance during the quarter? .............................................................. YES / NO

Pursuant to the CO emission limitations of ¶4.B.2.a.2, did the monitoring records under ¶6.B.2

show continuous compliance during the quarter? .............................................................. YES / NO

Pursuant to ¶6.B.3.c, were records of the non-emergency operation of the diesel-driven fire pump

maintained during the quarter? .......................................................................................... YES / NO

Have opacity screens been performed pursuant to ¶6.B.5? ............................................... YES / NO

Pursuant to ¶6.B.6, has natural gas sulfur content been monitored by:

○ maintaining a contractual commitment to purchase only conforming pipeline natural

gas?........................................................................................................................YES / NO

○ testing and analyzing gas on at least an annual basis? ......................................... YES / NO

Pursuant to ¶6.B.7, has diesel fuel sulfur content been monitored by maintaining a contractual

commitment to purchase only on-road diesel fuel? ........................................................... YES / NO

Pursuant to ¶6.B.8, have monthly rolling averages of power production, calculated as a function

of baseload, been maintained? .......................................................................................... YES / NO



○ Do those averages show compliance with ¶4.B.2.d? ............................................ YES / NO

Have repair logs been maintained pursuant to ¶6.B.9? ...................................................... YES / NO

Pursuant to ¶6.B.10, have monthly rolling averages of operating hours been maintained?

........................................................................................................................................... YES / NO

○ Do those averages show compliance with ¶4.A.2? ............................................... YES / NO

Pursuant to ¶6.B.11, have monthly rolling averages of startup operations been maintained? .YES /

NO

○ Do those averages show compliance with ¶4.A.3? ............................................... YES / NO

Pursuant to §6.E, on a separate sheet, describe and explain any previously un-reported deviations

from the terms of this permit. Is such a supplemental disclosure attached? ..................... YES / NO

Emissions report

Emissions of nitrogen oxides tons

Emissions of carbon monoxide tons

Emissions of particulate matter (PM10) tons

Emissions of volatile organic compounds tons

Emissions of sulfur dioxide tons

Certification by Responsible Official

I certify that, based on information and belief formed after reasonable inquiry, that the statements and

information in this report are true, accurate and complete.

Signed _______________________________________________

Printed Name __________________________________________

Title _________________________________________________

Date ________________ Contact Phone Number ___________

Mail to - Pinal County Air Quality Control District

PO Box 987

Florence, AZ 85132

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